The following comment was sent to the Natural Resources Conservation Service on August 22, 2023. The memo was prepared by the National Sustainable Agriculture Coalition with Michael Happ from the Institute for Agriculture and Trade Policy.
Thank you for the work you do for the United States' farmers, ranchers, and eaters, as well as our soil and water resources. On behalf of the National Sustainable Agriculture Coalition (NSAC), we are writing to share our recommendations for additions to the list of Climate Smart Agriculture and Forestry (CSAF) practices. For nearly forty years, NSAC has advocated for sustainable ways of growing our food and fiber that not only benefit the land and water we use to grow, but also the farmers tasked with stewarding these resources. We believe NRCS has been, and should continue to be, an essential partner in these goals.
Over the course of this document, we will go into detail as to why we believe these changes to the CSAF list should be made. Changes include increased cost-share, placing emphasis on certain existing CSAF activities, as well as additions and removals to the list. For your convenience, we have provided an abridged form of our proposed changes here:
Practices to be added:
- 317: Composting facility
- 331: Contour orchards and other perennial crops
- 336: Soil carbon amendment
- 516: Livestock water pipeline
- 555: Rock wall terrace
- 558: Roof runoff structure
- 588: Cross wind ridges
- 589C: Cross wind trap strips
- 595: Pest management conservation system
- 600: Terrace
- 633: Waste recycling
- 643: Restoration of rare and declining natural communities
- 658: Wetland creation
- 659: Wetland enhancement
- 823: Organic management system
Enhancements to be added:
- E328H: Conservation crop rotation to reduce the concentration of salts
- E328I: Forage harvest to reduce water quality impacts by utilization of excess soil nutrients
- E340E: Use of soil health assessment for development of cover crop mix to improve soil health quality
- E384A: Biochar production from woody residue
- E528N: Improved grazing management through monitoring activities
- E612A: Cropland conversion to trees or shrubs for long term improvement of water
- E612D: Adding food-producing trees and shrubs to existing plantings E612E: Cultural plantings
- E643A: Restoration of sensitive coastal vegetative communities
- E643B: Restoration and management of rare or declining habitat
Bundles to be added:
- Crop Bundle #20 Soil Health Assessment B000CPL20 Crop Bundle #21. Crop Bundle (Organic). B000CPL21 Crop Bundle #22. Erosion Bundle (Organic). B000CPL22 Pasture Bundle #5. Pasture. B000PST5
- Pasture Bundle #6. Pasture. B000PSTX Range Bundle #4. Range. B000RNG4
- Grazing Bundle #1. Range and Pasture. (B000GRZ1)
- Grazing Bundle #2. Range and Pasture. (B000GRZ2) Grazing Bundle #3. Range and Pasture. (B000GRZ3) Grazing Bundle #4. Range and Pasture. (B000GRZ4) Grazing Bundle #5. Range and Pasture (B000GRZ5)
Resource Concerns to be added:
- Climate change mitigation and adaptation
- Additional bundles should address:
- Multi-story agroforestry Crop-livestock integration
- Soil health management strategies for conventional and organic agriculture that include CPS 336, soil carbon amendment.
- Advanced soil health systems that include practices both within and beyond the cropping area
- Advanced grazing systems
Practices to be revised:
Practices to be removed:
- 366: Anaerobic digester
- 632: Waste separation facility
Enhancements to be removed:
- E328G: Crop rotation on recently converted CRP grass/legume cover for SOM improvement.
- E512E: Forage and biomass planting that produces feedstock for biofuels or energy production.
Over the course of this document, we will provide deeper context as to why we believe these practices, enhancements, and bundles should be added or removed from the CSAF list, or potentially revised. We also include principles for inclusion, and discussion of climate impacts, as well as impacts on farmers. Lastly, some recommendations not included in this cover sheet but included in the more in-depth recommendations are a renewed focus on certain CSAF activities that are high impact.
If you have any questions regarding our recommendations, please do not hesitate to reach out. Thank you for the work you do and for your consideration.
To continue reading the NSAC recommendations, please download a copy of the memo.
